The National Cyber Security Strategy 2020 (NCSS 2020) should promote encryption, protect decentralised internet, encourage robust data breach reporting mechanisms, prohibit the use of malware and reward the community of security researchers, the Internet Freedom Foundation wrote in its recommendations to the National Security Council Secretariat (NSCS).
The NSCS, which has been tasked with formulating the NCSS 2020 had invited comments for the same, and the last date of submission was January 10, 2020. Calling for transparency in the formulation of the strategy, IFF said that a draft of the proposed NCSS 2020 should be put out in the public domain following the first round of consultations.
It suggested that the task force which will formulate NCSS 2020 should consider digital rights of Indians, such as privacy, as complementary to a holistic cybersecurity approach. IFF added that NCSS 2020 should not see digital civil liberties and digital security as competing, because they are in fact complimentary.
Recommendations made by IFF
Encryption protects citizens, and in turn, the nation: Promotion of encryption should be one of the “primary focus areas” of the Strategy, since a failure to encourage it would put individual users at risk, who can be potential entry point vulnerabilities, IFF said. It said that concerns around encryption often fail to factor in the technical architecture of modern ICT devices, and the “many elements of personal data that are often outside of encrypted channels”.
- “Radically expansive” surveillance measures do not prevent cybersecurity breaches, and increase costs and resource deployment without advancing the security of individuals and government institutions, the organisation added.
Let the internet be decentralised: IFF cautioned against moving away from the decentralised framework of the internet, though several economic and regulatory forces are essentially threatening that decentralisation. It said that consolidation of the telecom sector will not only limit the diversity of network architectures, but also inhibit user choice and increase the risk of a single point of failure.
- Regulations that seek to centralise databases containing sensitive personal information of Indians, and proposals to create data exchange networks around community data, also raise similar concerns, IFF noted, and added that this negatively affects cyber security in “real and tangible” ways.
Devise strong data breach notification mechanisms: The task force should make a strong case in support of the proposed data breach notification provision in the Personal Data Protection Bill before Parliament, since such a provision will enhance cybersecurity “immensely,” IFF said. Also, the proposed Data Protection Authority in the Bill should be involved in any national cybersecurity coordination mechanism, it added.
Ban malware: Use of malware “should be clearly prohibited” in the NCSS 2020, IFF said. Zero-day hacks and an increase in the use of technical exploits to hack into devices and digital services of Indian citizens also makes India insecure, it noted, adding that individuals can use these tools to create backdoors.
Reward security researchers: The policy should account for a standard operating procedure for departments to be notified by security researchers, IFF said. They should be rewarded for “upholding and securing our [India’s] national interest,” and the government should adopt bug bounty programmes and responsible vulnerability mechanisms, the organisation submitted.
[embeddoc url=”https://www.medianama.com/wp-content/uploads/IFF-comments-to-National-Cybersecurity-Strategy-Consultation-Jan-2020-1.pdf” download=”all”]